On 1 July 2026, the European Securities and Markets Authority (ESMA) published a consultation paper on technical advice on selected key performance indicators (KPIs) under the Disclosures Delegated Act (Commission Delegated Regulation (EU) 2021/2178).

Background

Earlier this year the European Commission (Commission) invited the European Supervisory Authorities to provide targeted technical advice to support the review of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation. The consultation paper now published responds to this request and seeks to gather feedback on targeted proposals aimed at improving the usability, relevance and proportionality of the Taxonomy reporting framework.

In particular, the consultation paper seeks views on:

  • The current limitations of the operational expenditure KPI, including its narrow-perceived relevance and operational complexity. ESMA sets out several alternative approaches to revising the KPI, ranging from targeted refinements to more fundamental redesign options, and presents ESMA’s preliminary preference for an approach that limits the operational expenditure to research and development expenditure. ESMA is also consulting on the possibility of accompanying this revised mandatory operational expenditure KPI with optional reporting of an additional KPI, capturing other operating expenditures relevant to an undertaking’s efforts on green procurement and possibly other expenditures.
  • Voluntary use of operational expenditure by financial undertakings. ESMA’s preliminary analysis indicates that the usefulness of operational expenditure for financial undertakings depends on how the KPI is revised and its voluntary reporting may increase complexity while providing only marginal additional information value.
  • Group Taxonomy reporting. ESMA identifies certain challenges in the current framework for mixed groups and financial conglomerates. It proposes an approach based on a primary reporting regime determined at group level, complemented by targeted disclosures to avoid material information gaps.
  • Additional possible simplifications including simplifications concerning the reporting obligations of non-financial undertakings in relation to Annex I of the Disclosures Delegated Act.

Next steps

The deadline for comments on the consultation paper is 12 August 2026.

ESMA will hold a public hearing to present the proposals and engage with stakeholders on 22 July 2026.

ESMA intends to deliver its final technical advice by end-October 2026, as requested by the Commission.